The Coastguard, Emergency Towing Vessels and the Maritime Incident Response Group - Treasury Contents


Further written evidence from the Chief Fire Officers Association (CFOA) (MCA 19a)

INTRODUCTION

1.  CFOA is the professional voice of the UK Fire and Rescue Service (FRS), supporting its members to fulfil their leadership role in protecting our local communities and making life safer through improved service delivery. CFOA provides professional advice to inform Government policy and is committed to developing both strategic and technical guidance and sharing notable practice within the wider FRS.

2.  Membership of the Association comprises almost all the senior management of FRS in the United Kingdom. CFOA is the driving force in managing change and implementing reforms in the Service.

3.  CFOA has previously provided written evidence relating to the Maritime Incident Response Group (MIRG) for the Transport Select Committee (TSC) inquiry held on 8 February 2011.

4.  The attached submission will expand on and make reference to the initial evidence to inform the new inquiry that is to be conducted by the TSC into the Coastguard, Emergency Towing Vessels and the Maritime Incident Response Group.

MARITIME INCIDENT RESPONSE GROUP

5.  In 2010, the Maritime and Coastguard Agency (MCA) commissioned an independent "Review of Requirements in Relation to Assisting with Incidents Involving Fire, Chemical Hazards and Industrial Accidents at Sea" (MCA Consultancy Project Ref CO96).

6.  This review was undertaken at a direct cost to the MCA of £81.9K by BMT Isis Ltd and concluded in October 2010 in the form of a 233 page report.

7.  The report is underpinned by an assessment of risk around the whole of the UK coastline and proposes a reasonable worst case scenario that would involve "a passenger vessel fire that potentially needs to be controlled for up to two days, has the potential to cause loss of life and cannot be contained by the ship's finite resources".

8.  The primary aim regarding passenger ship emergencies is to maintain the integrity of the ship so that the ship does not have to be evacuated at sea. Large passenger ship design is regulated by the International Maritime Organisation (IMO). A review of passenger ship safety by the IMO has determined that such ships should be so designed that fires or flooding should be contained by means of sub-division; and that the ship should remain upright so that she can reach a place of safety with her passengers and crew safe aboard.

9.  While the intention is that the ship should be so designed and equipped and her crew so trained that she should be able to deal with fires aboard from her own resources until she reaches port, the IMO have also recognised the need for external support.

10.  The IMO's Maritime Safety Committee (MSC) published a Circular in 2006, "Guidelines on the provision of external support as an aid to incident containment for Search And Rescue authorities and others concerned" (MSC.1/Circ.1183). The Circular lists, inter alia, "fire-fighting personnel and equipment" as its prime example of such support:

11.  "Teams of shore-based fire-fighters, suitably trained and equipped for incidents at sea, may be brought to the ship in distress by helicopter and/or by surface craft, to advise and assist the ship's crew in tackling and/or containing fires, smoke, and/or chemical hazards arising from spilled, leaking or burning materials. Fire and/or salvage teams may also be able to bring additional equipment to the ship to assist in dealing with such hazards." (MSC.1/Circ.1183, paragraph 2.1.1)

12.  The overarching MIRG FRS strategy for this scenario at sea, is to stabilise and contain the incident sufficiently to prevent a mass evacuation until the casualty vessel can be brought alongside and sufficient resources deployed to conclude the incident. This strategy fully supports and aligns with the ethos of the IMO MSC guidance.

13.  It is well-documented that the masters of ships dealing with fires at sea very much welcome such support, and especially professional firefighting advice. The alternative may be a complete or precautionary partial evacuation of the ship at sea, exposing passengers and non-essential crew to very significant additional risks.

14.  Two approaches are utilised to provide the assessment of risk undertaken by BMT Isis Ltd. The first which is based on a dataset provided by the Marine Accident Investigation Branch (MAIB) considers fires that had the potential to cause multiple fatalities within UK territorial waters.

15.  The report identifies that the overall frequency of these potential incidents is approximately two per year for the whole of the UK and that "this approach identifies that a response capability is required for all of the UK coastline".

16.  The second approach identifies fires that have actually occurred in Europe within the last 50 years and have resulted in multiple fatalities involving passengers. The report estimates that the probability of such an incident in UK waters is 1 in 100 per year and concludes "that the second approach corroborates the finding that a response is required".

17.  Both of these approaches determine that the potential risk exceeds the tolerable/intolerable risk threshold identified within the report as the probability of an incident being greater than 1 in 1000 per year.

18.  The report authors identify that the Civil Contingencies Act 2004 Guidance on Emergency Preparedness considers a "Significant" transport accident scenario as one in which the accident involves 10 fatalities and further that the guidance "states that an incident with a likelihood of 1 in 200 over a five year period (equivalent to 1 in 1,000 per year where the incident rate is constant) is described with a likelihood of 'Level 3—Unlikely'".

19.  The Guidance also proposes that for the reasonable worst case scenario, with a likelihood of "Unlikely" and an impact of "Significant" since it is a transport accident that would result in more than 10 fatalities, the risk classification of this scenario is "Very High Risk".

20.  The guidance defines "Very High Risk" as:

"These are classed as primary or critical risks requiring immediate attention. They may have a high or low likelihood of occurrence, but their potential consequences are such that they must be treated as a high priority. This may mean that strategies should be developed to reduce or eliminate the risks, but also that mitigation in the form of (multi-agency) planning, exercising and training for these hazards should be put in place and the risk monitored on a regular frequency. Consideration should be given to planning being specific to the risk rather than generic";

21.  The Appendix provides a breakdown of passenger vessel fires that have occurred within International, European and UK waters since 1963. These incidents substantiate the worst case scenario as above, in some examples with a significant loss of life.

22.  Whilst UK waters have not yet experienced a passenger vessel fire culminating in loss of life there are several recorded incidents where this potential existed. The first deployment of MIRG (May 2006) to the Cruise Ship Calypso occurred within one month of its introduction. The vessel had 708 people on board and requested assistance to deal with a serious engine room fire. Her Master considered a partial evacuation of the ship, at night, in the Dover Strait Traffic Separation Scheme as a precaution. Deployment of the MIRG helped avoid this scenario and the resultant risks to the safety of the passengers.

23.  Unfortunately within European waters there have been incidents involving fire that have resulted in a significant loss of life.

  • The LAKONIA 128 fatalities.
  • The SCANDINAVIAN STAR 159 fatalities.
  • The MOBY PRINCE 143 fatalities.

24.  Anecdotal evidence also supports the BMT Isis Ltd assessment of risk. The MCA "Consultation on Proposals for Modernising the Coastguard document (2010), considers that 'our seas are becoming more congested', 'ships are getting larger' whilst the 'coastline is getting busier'."

25.  There is increasing demand and scale within the Cruise Liner industry which represents one of the largest growing sectors of the holiday market (Department for Transport (DfT) statistics).

26.  The expansion of green energy sites at sea and the associated numbers of people that will be located within these areas will provide for significant future life risk.

27.  It is envisaged that there will be a significant increase in passenger numbers arriving in UK ports in the lead up to the London 2012 Olympic Games. Any incident involving fire on a passenger vessel will provide for high profile international interest, whilst presenting an increased risk to Coalition Government priorities and DfT business objectives "contribute to a successful 2012 Olympics" (Business Plan 2011-15).

28.  CFOA is a current member of the Association of Chief Police Officer's Maritime Advisory Group (MAG), a national, multi agency community that has been established to assist in the development of measures to ensure the effective co-ordination of the national response to a Maritime Terrorist incident within UK waters and surrounding seas. Within this context the group has considered if MIRG would have any capability to assist in a terrorist marine incident, either along the lines of London 7/7 or in a post Chemical Biological Radiological Nuclear (CBRN) scenario. Preliminary work has identified that subject to a "permissive environment" having been established, MIRG could provide a capability if required to assist in resolving the consequences arising from terrorist activity on a ship.

29.  The DfT, Transport Spending Review Press Notice (20/10/10) Annex F, announced that a review of MIRG would be undertaken and that "since the MIRG teams began operating in 2006 they have not been involved in any significant incidents. All ships' crews are trained in basic fire fighting techniques and there is little evidence that MIRG has changed the outcome of ship fires".

30.  Fire fighting training that ships crews undertake is regulated by The Standards of Training, Certification & Watch keeping (STCW) Convention. All mariners are initially required to undertake basic training in fire prevention and fire fighting, a two day course, and may subsequently undertake advanced training in fire fighting, a four day course, subject to requirements set out in Section A-VI/3 of the STCW Code.

31.  Within the convention there is no requirement for any revalidation and /or additional fire fighting training.

32.  The MIRG have attended six significant incidents at sea since its inception. In each case there has been the potential for loss of life and the Ship's Master had requested assistance in the form of additional fire fighting resources to augment the vessels capability.

33.  Each MIRG deployment has provided the Master with an additional, highly trained and professional resource that can assist them with both the strategic and tactical dimensions of a fire incident on board their vessel.

34.  The MAIB investigation (Report No 8/2007) into the Calypso incident above reported that the MIRG "provided much needed support and advice to the ships master and to the rescue authorities".

35.  The Marine Safety Act 2003 provides for powers of intervention and directions to the Secretary of States Representative (SOSREP) inclusive of powers in relation to places of refuge. In determining a suitable place of refuge a risk assessment must be carried out by the SOSREP to carefully consider both the economic and environmental impact to the UK if the incident deteriorates.

36.  As the use of places of refuge could encounter local opposition and involve political decisions the UK Government has recognised that a properly argued technical case, based on a clear description of the state of the casualty, would be of great value in any decision making which may take place.

37.  The most recent MIRG deployment (October 2010) was to the large fish factory vessel ATHENA from which 81 persons evacuated whilst the crew remained to contain the fire. MIRG was deployed to this incident at the request of the SOSREP to provide an at sea assessment on the condition of the ship and to assist in the containment of the fire. MIRG also provided an invaluable link between the vessel and the Local Authority FRS within whose area of responsibility the vessel would ultimately berth.

38.  The Review report identifies that MIRG currently provides a professional, specific and specialised response to incidents at sea. A commercial replacement of the MIRG would be expensive and that "The existing form of provision (MIRG) has inherent cost advantages because all the basic training and non-MIRG Firefighter training time is funded elsewhere".

39.  It considers that the most appropriate option identified for future provision of an at sea response to fire, chemical hazards and industrial accidents is a continuation of the MIRG model but with a realignment to match the resources to the identified risk.

40.  Cognisant of the Review findings the current MIRG provision has been assessed with a view to realigning to the identified risk. It is considered that UK MIRG resilience arrangements could continue to be maintained within nine FRS's with a reduction in the cadre of specialist Fire-fighters necessary in each.

41.  The MCA currently provide £600k direct funding to support the MIRG provision, whilst the FRS collectively provides an equal amount. The annual direct funding requirement from the MCA necessary to maintain the revised arrangements would be in the order of £340k, a significant reduction on the previous figure of £600k.

42.  The previous evidence submitted by CFOA to the TCS inquiry provided the background to the "Sea of Change" project and the subsequent introduction of the MIRG. An increasing decline in UK resilience for dealing with fires at sea and the fallout from a fire on board a vessel in the North Sea in 2001, provided the catalyst for the "Sea of Change" project, which at the request of the Secretary of State for Transport was commenced by the MCA in partnership with CFOA in January 2003. In April 2006, 3 years after the commencement of the project, the Secretary of State for Transport formally launched the implementation of MIRG.

CONCLUSION

43.  The independent assessment of risk conducted by BMT Isis Ltd considers that there is a "Very High Risk" of a "Significant" incident involving a passenger vessel at sea within the territorial waters of the UK. "The risk assessment has confirmed that a response is needed around most of the UK, to attend and contain vessel fires with the purpose of preventing loss of life". That "Eliminating the provision is not considered an option" in the context of the identified risk.

44.  Whilst there is no statutory duty on the MCA or FRS to make provision for a response to fires at sea, the current financial support provided by the MCA and equally matched by the FRS, ensures an integrated, interagency national strategy for dealing with incidents in the maritime environment.

45.  The independent review commissioned by the MCA concludes that MIRG provides a cost effective and timely emergency response to incidents Involving Fire, Chemical Hazards and Industrial Accidents at Sea. "Any commercial equivalent would be expensive and unlikely to constitute an emergency service".

46.  A revised cost effective MIRG model has been proposed that will maintain the current UK resilience to deploy FRS assets to incidents at sea.

47.  Without the provision of the necessary funding to maintain the role of the MIRG it will quickly fall into decline and become vulnerable to similar issues which first initiated the formation of the "Sea of Change" project.

48.  There will be no provision for the UK to deploy FRS resources to vessels at sea within significant areas of the United Kingdom Search and Rescue Region (UKSRR), this within the context of the Review findings and an escalating risk profile.

49.  This issue is entering a critical phase in respect of funding. Individual MIRG FRS's are currently in the process of presenting papers to their respective Fire Authorities to determine the continuation or withdrawal of their involvement in MIRG. Early indications are that the majority, if not all, FRS would not be able to continue to provide this capability if the funding currently provided by the MCA is withdrawn.

50.  MIRG has an important role to play in the safety of passengers travelling by sea off the UK coastline and this has been recognised in the Review report. It is an extremely cost effective model that has been developed and enhanced over a number of years and an excellent example of partnership working across Government departments. CFOA would encourage the Transport Select Committee to recognise the service provided by MIRG teams across the UK and recommend its continuation through the provision of adequate national funding.

APPENDIX

PASSENGER VESSEL FIRES—DATA REPRESENTATIVE OF WORST CASE SCENARIO (WORLDWIDE)
TypeLocation YearName Crew at RiskPassenger at Risk Total at RiskTotal Injuries Total Fatalities
CSEU1963 Lakonia385651 1036-128
CSINTER1965 Yarmouth Castle174375 549-89
CSINTER1966 Viking Princess259235 494252
CSEU1970 Fulvia271448 719--
CSINTER1971 Antilles300350 650--
CSEU1971 Heleanna94>1,000 >1,09415025
CSINTER1974 Cunard Ambassador290 -290--
CSINTER1976 Mecca761,105 1,181--
CSINTER1977 Rasa Sayang340653 993--
CSINTER1979 Angelina Lauro350650 1000--
CSINTER1980 Prinsendam204320 52424-
ROINTER1981 Tampomas II821,054 1,136-666
ROINTER1981 Arion105250 400-1
CSEU1982 Mediterranean Star- 1,0001,000- -
CSINTER1985 Chidambaram186702 888-40
CSINTER1988 Priamurye129259 3883511
ROEU1990 Scandinavian Star99 383482- 158
CSEU1991 Pegasus20938 247--
ROEU1991 Moby Prince6874 142-141
CSEU1992 Seabourn Spirit148178 326--
CSINTER1994 Regal Empress3001,200 1500--
ROUK1994 Sally Star10417 121--
CSINTER1995 Albatross311565 876--
CSINTER1995 Regent Star-1,284 1,2847-
ROINTER1995 Kimelody Christy-- --14
CSINTER1996 Universal Explorer271 732100356 5
CSINTER1997 Romantica186487 673--
CSINTER1997 Vistafjord422569 991151
CSINTER1998 Ecstasy9162,565 348122-
ROEU1999 Supafast III106307 41310-
CSINTER1999 Sun Vista-472 472--
ROINTER1999 Dashun->300 >300280-
ROINTER2001 Tonghui-32 32-6
ROINTER2002 Al Salam Petrarca 9068 896964- 1
ROINTER2002 Maria Carmela-346 3468644
ROINTER2004 Superferry 14-889 899-194
ROINTER2007 Butuan Bay-513 5133-
ROINTER2007 Catalyn - D-237 237-28
CSUK2006 Calypso-708 708--
CSINTER2006 Star Princess11502,600 3,750111
CSINTER2008 Queen of the West53 1241771 -
ROINTER2009 Mandiri Nusantara24 350374- 5
CSEU2010 Deutschland241364 605--
CSINTER2010 Carnival Splendor1,167 3,2994,466- -
ROUK2010 Oscar Wilde113- 113--
ROUK2010 Commodore Clipper39 62101--
ROEU2010 Lisco Gloria-236 23623-
ROINTER2011 Laut Teduh 2-477 477-28

CS = Cruise Ship  

RO = Ro-Ro/Passenger Vessel

April 2011



 
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© Parliamentary copyright 2011
Prepared 23 June 2011